Gutierrez v. Astrue
Filing
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ORDER by Magistrate Judge Maria-Elena James granting 8 Stipulation (rmm2S, COURT STAFF) (Filed on 8/1/2012)
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Geri N. Kahn, Esq., SBN 148536
400 Montgomery Street, Suite 810
San Francisco, CA 94104
Tel. (415) 397-5446
Fax (707) 361-0350
Email: gkahn@pacbell.net
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN FRANCISCO DIVISION
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Candida GUTIERREZ,
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Plaintiff,
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vs.
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MICHALE J. ASTRUE, Commissioner of
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Social Security,
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Defendant.
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Case No.: 3:12-cv-01390-MEJ
STIPULATION TO EXTEND DUE DATE
OF PLAINTIFF’S BRIEF IN SUPPORT OF
HER MOTION FOR SUMMARY
JUDGMENT; AND [PROPOSED ORDER]
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Plaintiff, by and through her attorney of record, and Defendant, by and through
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his attorney of record, hereby stipulate, subject to the approval of the Court, to a 60-day
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extension of time for Plaintiff’s counsel to file a brief in support of her Motion for
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Summary Judgment, in light of the following:
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1.
Plaintiff’s counsel is a sole practitioner and has other matters with
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approaching deadlines. The transcript in this proceeding is over 500
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pages. Plaintiff’s counsel needs additional time to review the transcript
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and to write the Motion.
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Stipulation of Extension of Time to File S/J, 3:12-cv-01390 MEJ - 1
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2.
Plaintiff’s counsel has spoken with Theophous Reagans, Esq.,
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defendant’s counsel and he has indicated that he is agreeable to a 60 day
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extension of time for counsel to prepare her brief.
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3.
Should the request be granted, Plaintiff’s brief will be due on October 1,
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2012, Defendant’s reply brief on October 31, 2012 and Plaintiff’s optional
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response brief on November 14, 2012.
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Respectfully submitted,
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Dated: July 31, 2012
/s/ Geri N. Kahn
GERI N. KAHN
Attorney for Plaintiff
Dated: July 31, 2012
/s/ Theophous Reagans
THEOPHOUS REAGANS
Special Assistant United States Attorney
Attorney for Defendant
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ORDER
Pursuant to stipulation, IT IS SO ORDERED.
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Date: August ___, 2012
Maria-Elena James
United States Magistrate Judge
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Stipulation of Extension of Time to File S/J, 3:12-cv-01390 MEJ - 2
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